Hector Prowse - Page 2

                            T.C. Summary Opinion 2007-31                              


                               UNITED STATES TAX COURT                                


                            HECTOR PROWSE, Petitioner v.                              
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 17121-05S.           Filed March 1, 2007.                   

               Hector Prowse, pro se.                                                 
               Marc L. Caine, for respondent.                                         


               COUVILLION, Special Trial Judge: This case was heard                   
          pursuant to section 7463 in effect when the petition was filed.1            
          The decision to be entered is not reviewable by any other court,            
          and this opinion should not be cited as authority.                          



               1 Unless otherwise indicated, subsequent section references            
          are to the Internal Revenue Code in effect for the years at                 
          issue.  All Rule references are to the Tax Court Rules of                   
          Practice and Procedure.                                                     




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